The U.S. and Australia have Similar, but Distinct, Stove Regulation Strategies.

Australia is in the process of developing stricter emission standards for wood heaters and their approach is a fascinating glimpse into another regulatory culture. The strategies and cost – benefit analysis in Australia should be a valuable comparison for the EPA as it finalizes its New Source Performance Standards (NSPS) for US wood heaters. This post is an overview of an Australian report showing the financial gains created by stricter regulations on wood heaters.

In 2011 the Council of Australian Governments (COAG) identified air quality as a Priority Issue of National Significance and agreed that the COAG Standing Council on Environment and Water (SCEW) would develop a National Plan for Clean Air to improve air quality, and community health and well being, to be delivered to COAG by the end of 2014. The first stage of the National Plan for Clean Air will focus on particle emission reductions and a consultation Regulation Impact Statement which assesses alternative policy options that could be employed to reduce emissions from wood heaters in Australia, and establishes their relative costs and benefits.

The current Australian Standards that cover wood heater emissions and efficiency set a criterion of 4 grams of particulate matter (PM₁₀) per kilogram of fuel brunt (4g/kg). There is currently no efficiency criterion, but efficiency results must be reported on a label permanently attached to the appliance.

The report showed a large range of potential policy measures that could be implemented to reduce emissions from wood heaters. The potential measures fall into three major categories:

• wood heater design or performance standards;
• measures to promote compliance of retail models against these standards; and
• measures influencing the in-service operational performance of wood heaters.

These measures could be delivered through a range of policy 'vehicles'. The policy delivery approaches examined are a voluntary national program, a collaborative approach or a national regulatory approach.

Under the business-as-usual or 'base case' scenario, particulate emissions from wood heaters in Australia are expected to fall by around 5000 tons (or 12%) over the next twenty years, as old heaters are progressively replaced with new, lower particulate emitting heaters. The reduction in annual particulate emissions from wood heaters under the policy options examined, over and above the business-as-usual reductions, range from 3% to 18%.

The estimated costs to government of implementing the different policy options range from $15 million over the next twenty years to around $39 million. The estimated costs to manufacturers range from $240,000 to $17 million, the strictest boasting an efficiency standard of 60% as well as an emission limit of 1.5 g/kg. The health benefits of the options are estimated to range from $760 million to around $1,850 million over the twenty year assessment period. Although the greatest emission reductions are estimated for the most expensive option, the highest health benefits are estimated for another which has a shorter phase-in period for the new standards. The estimated benefits far outweigh the estimated costs of all options included in the analysis. The present value of the net benefits range from around $750 million to $1,800 million.

The report concludes the greatest net benefits are likely to be achieved via a national regulatory approach for managing wood heater emissions, rather than through a voluntary or collaborative approach. This could be achieved either through a Commonwealth regulation, a National Environment Protection Measure (NEPM) or through mirror legislation.

View the full report here.

Webinar Announcement

Innovation and the NSPS:

How can the EPA encourage innovative new technologies?

1:00-2:00 PM ET
Thursday, May 9, 2013

EPA regulations for biomass heating devices often have addressed one set of problems, and inadvertently led to others as technology developed. The EPA has stated that in the next wood heater New Source Performance Standard (NSPS), it wants to “minimize potential loopholes.” How can the NSPS encourage and not discourage new technologies that may be cleaner and more efficient, but have difficulty with approved test methods? What lessons have we learned from the existing NSPS and EPA voluntary programs? Register for the May 9 webinar to begin discussion >>

This webinar is being held in the lead up to the Wood Stove Design Challenge, a national competition to promote extremely clean, efficient, innovative and affordable cordwood technology.

Although there will be a Question and Answer session, questions are requested in advance and should be submitted to info@forgreenheat.org by COB Monday, May 6. This webinar is co-hosted by the Biomass Thermal Energy Council and the Alliance for Green Heat.

Speakers

• Mr. Gil Wood, Project Lead, NSPS Program, Environmental Protection Agency 
• Moderated by John Ackerly, President, Alliance for Green Heat 
• Welcome by Joseph Seymour, Executive Director of the Biomass Thermal Energy Council

Attend the webinar and learn

• How the NSPS applies to residential biomass heating equipment
• What procedures, qualifications, emissions limits, and technologies are under consideration for the draft NSPS rule
• The comparative changes from the existing and draft NSPS
• How the new NSPS would promote and handle innovative technologies
• Will this NSPS drive innovation by requiring industry to meet strict emission limits?
• Question and Answer session with the speaker (questions are requested in advance)

Registration Information

• Cost: Free
• Time: Thursday, May 9th @ 1PM ET - 2PM ET
• Registration: https://www2.gotomeeting.com/register/946864810

 Send any questions to info@forgreenheat.org.

EPA Changes Strategy Again; Will Now Phase in Stricter Standards for Biomass Stoves and Boilers

Alliance for Green Heat, April 1, 2013 - The EPA released information about the New Source Performance Standards (NSPS) this month after making many changes to accommodate state demands for cleaner stoves and boilers. The new draft NSPS will do little to make most wood and pellet stoves cleaner until 2017 or 2019 but will have immediate impact on biomass boilers. All classes of heaters will have to meet stricter “best systems” emissions standards in 2017 or 2019, depending on whether EPA uses a two or three-step approach.

The draft NSPS appears to treat all biomass stoves, pellet or wood, catalytic or non-catalytic, the same and require that they emit no more than 4.5 grams of fine particulate emissions (PM2.5) per hour, a standard that has been in place in Washington State since 1995. The average pellet stove today emits about 2 grams per hour, already less than half of the proposed standards.

Hydronic heaters, commonly known as outdoor wood boilers, would also be held to existing standards that were developed about 5 years ago. However, the new NSPS would regulate sales and installations of these appliances across the entire country, instead of just the approximately 10 states that have adopted the voluntary EPA standard. 

While the new NSPS may reflect the status quo in many states in the near future, it could become far stricter for both stoves and boilers. In 2019, the test method for measuring stove emissions could change, for example, from averaging four burn rates to using only the highest or lowest burn rate (depending on which one the stove has the hardest time passing). Some in the industry think this standard will be a death-blow for stove manufacturers. Other experts say it will be achievable, but the stoves that will be made may not be as appealing to consumers.

The written document EPA released this month did not contain any numerical limits that industry would have to meet in the future, but Gil Wood, EPA’s lead official on this NSPS verbally shared numbers with roomful of stove and boiler manufacturers who had gathered in Orlando Florida for the annual HBPA Expo. The Alliance for Green Heat requested a copy to make available to the public, which the EPA provided.

The EPA has backed off of creating a required minimum efficiency standard, which all other HVAC technology has, in favor of testing and publicly reporting efficiency to the consumer. The industry position is that reporting efficiency is sufficient and enables the consumer to decide if they want the equivalent of a gas guzzler or a gas miser as their home heating appliance.

There is much speculation about how the new EPA Administrator, Gina McCarthy, will impact the NSPS.  Administrator McCarthy had been head of the air quality division at EPA and has a good working knowledge of solid fuel appliances. And, McCarthy has already reportedly asked tough questions about why fireplaces are not covered in this NSPS. 

Many in industry are simply tired of an agency that appears to keep changing its mind about how strictly wood heating appliances should be regulated. As of last fall, EPA appeared to have something close to a final draft of the new NSPS that was more acceptable to industry but considered far too weak by many states. 

States now appear to have strengthened their hand. By adopting a stepped approach, the new NSPS may do little to make stoves or boilers any cleaner before 2019 in the Northeast and Northwest, where states have already adopted standards that are as strict as or even stricter than what the EPA is proposing. 

The most immediate impact upon promulgation, which could be in 2014, is that unregulated outdoor wood boilers would go off the market in all states. But there is a growing movement that feels even Test Method 28 WHH and standards for EPA qualified outdoor boilers still are deeply flawed, even after Method 28 OHH was improved to Method 28 WHH. It is still unclear how boilers will be tested for 2014 compliance and how existing voluntary tests will be validated. 

Brookhaven National Laboratory recently completed a study that resulted in a new test method being created for both outdoor wood boilers and indoor boilers that have partial thermal storage. Funded mainly by NYSERDA with some support from EPA, this method draws upon the ASTM method and Method 28 WHH. It can be used instead of Method 28 WHH for any boiler with partial thermal storage. New York State has already accepted the test method which will help open up the state up to European and American boilers with thermal storage. 

The Brookhaven Method is also similar to the ASTM Method 2618 and could replace that method as well, but has it has not yet been introduced into the ASTM process. The test method is more stringent than Method 28 and the European EN 303-5 but it may be a quicker and cheaper test for manufacturers to undertake.  It is still unclear if the Brookhaven method could be part of this NSPS or not. That will likely depend on how much the states push for it and whether industry pushes back. 

The EPA’s latest timetable suggests it will have a final draft of the new NSPS ready for internal review in April and the agency will publish the standard in the Federal Register this summer. Industry, states, non-profits and the public will then have 90 days within which to submit comments. The final rule would be promulgated and go into effect in the summer of 2014.

 

The EPA has yet to meet any of their timetables for this NSPS. There is always the chance that someone will sue the EPA simply to get a court-ordered timetable that it would have to adhere to. And, lawsuits based on substantive regulations are also possible, if not likely, from a variety of fronts, if acceptable compromises cannot be reached.

Groups Press EPA for Action on NSPS

Alliance for Green Heat, January 4, 2013 - A number of organizations have been formally weighing in with the EPA well ahead of the much anticipated 90 day comment period that starts when the New Source Performance Standards (NSPS) is finally published in the Federal Register. To be fair, the organizations are mostly calling on the EPA to move quicker and finalize the NSPS, but they also contain many substantive recommendations for the NSPS.

Letters from the American Lung Association (ALA), the Economic Council of States and NESCAUM and WESTAR can be publicly found on the internet, but far more detailed recommendations and lobbying between HPBA, ALA, NESCAUM, states and EPA is not very transparent. An enormous amount of communication, positioning, chest pounding and all other manner of persuasiveness has intensified this fall as the EPA has re-opened the door for changing the draft NSPS. The last we heard, the NSPS was going to OMB in January, and they would review it for 90 days before publishing it in the spring.